Category Archives: HSA mechanics

Health Savings Account Deadlines

Overview

Health Savings Accounts function by tax year. So 2017 is distinct from 2018, so on and so forth. Each tax year that you have HSA coverage gives you the opportunity to contribute to your HSA up to your contribution limit. However, eventually that tax year passes and you can no longer contribute to your HSA for that year. This article discusses when those timelines are and how to get the most out of your HSA for a year before the deadline.

HSA Current Year Contribution Deadline

For a given tax year, you can contribute normally to your account from January 1st until December 31st. You can contribute whatever amount you want at any time. This means that some people put the full year’s contribution in on January 1st, some contribute a pro-rata 1/12th each month, and others wait until the end of the year to make the contribution. The only risk you run by contributing early (say, in January) is over contributing. If you contribute the full amount in January, and subsequently end HSA eligible insurance, you will have excess contributions in your account that you need to remove.

The point is you can contribute to your HSA any time during the tax year. But what if you wait too long and miss that deadline?

HSA Prior Year Contribution Deadline

Luckily, the IRS is quite lenient and let’s you make prior year contributions to your Health Savings Account. This means that for a few months in the following tax year, you can make a contribution but flag it as a contribution for the prior year. The deadline for this prior year contribution is the day your taxes are due, generally April 16th.

You have up until tax day (generally April 16th) to make contributions to your Health Savings Account for the prior year. You can make contributions to your HSA for 2016 until April 18, 2017.

Note that making a prior year contribution requires a simple but special action taken with your HSA custodian. When you make the contribution, you will have to indicate specifically that it is going towards the prior tax year. This is because a contribution made in say, January, can be used for either the current year or prior year. Your HSA custodian needs to know how you handle this contribution and to which tax year you want it to count. When you make the contribution there should be an indicator for the tax year, so make sure you pick the correct one.

The IRS outlines the legalities of this in HSA Form 969:

You can make contributions to your HSA for 2016 until April 18, 2017. If you fail to be an eligible individual during 2016, you can still make contributions, up until April 18, 2017, for the months you were an eligible individual.

The interesting thing this points out is you do not need to remain an eligible individual to make prior year contributions. This means that your HSA insurance can end, but you can still wait until the following year to make prior year contributions. As an example, say you have HSA eligible insurance from January – June of 2016. Even if you contribute nothing in 2016, and even though your HSA eligible insurance has ended, you have until April 18th (tax day) of 2017 to make your full contribution limit for 2016. In this case, that would be 6/12 or 1/2 of the full contribution limit for 2016, since you had coverage for 6 months.

Deadline for HSA Employer Contributions

In addition, the deadline for employers to make contributions to your HSA for a given year is also tax day of the following year. Per IRS Form 969:

Your employer can make contributions to your HSA between January 1, 2017, and April 18, 2017, that are allocated to 2016. Your employer must notify you and the trustee of your HSA that the contribution is for 2016. The contribution will be reported on your 2017 Form W-2.

Note that the prior year employer contribution will be reported on your current year W2. This means that it will show as non-taxable income, and won’t affect that year’s contribution limit, but note that it will be there.

TrackHSA record keeping

HSA Deadline for Reimbursement

One of the benefits of an HSA is there is no true deadline for reimbursing a qualified medical expense. To explain further, note that you can purchase health care using 1) your HSA or 2) something other than your HSA, such as a credit card or cash. If you buy a qualified medical expense with something other than your HSA, you are allowed to “reimburse” yourself for that expense at some point in the future. This reimbursement involves transferring funds from your HSA to yourself, generally the checking account. This in effect pays for the purchase with the HSA, giving you tax free medical spending.

Why would you want to do this? The benefit is that you can keep funds in your HSA longer. If you are investing your HSA, those earnings on HSA funds are growing tax free. By leaving purchases “in” your HSA and fully invested, not only is that money growing, but it is growing tax free, which is a huge IRS advantage. In addition, this reimbursable amount functions as a rainy day fund for you. You are allowed to reimburse it at any time, so if you ever need cash it can be quite helpful.

This is why record keeping and recording your HSA purchases is so important. You need to know what you have purchased, how it was paid, and whether it has been reimbursed or not. These needs were a big reason why I created and use TrackHSA.com, as it provides an audit trail for all of your HSA activity with which you can justify transactions to the IRS should they come knocking.


Note: if you need help accounting for your HSA contributions come tax time, please consider using my service EasyForm8889.com to complete Form 8889. It asks simple questions in a straightforward way and will generate your HSA tax forms in 10 minutes. It is fast and painless, no matter how complicated your HSA situation.


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How to Determine if You Used the HSA Last Month Rule

Overview

This is a fairly common question I get from readers regarding the HSA’s Last Month Rule and how to file Line 18 on Form 8889. The question usually takes the form of:

  • “Did I use the Last Month Rule last year?”
  • “Do I owe anything for the Last Month Rule?”
  • “What should I put on Line 18 of Form 8889 where it says Last Month Rule?”

Luckily, it should be easy to figure out whether the Last Month Rule even applies to your tax return. The goal of this article is to explain how the Last Month Rule works, and then ask 3 questions to see how it applies to you.

What is the Last Month Rule?

Let’s start by defining some terms. The Last Month Rule is a “feature” of HSA’s that generally only applies to a year that you begin HSA eligible coverage. It states that if you are an eligible individual as of December 1st of a year, you are treated as an eligible individual for that entire year. This is a benefit as it allows you the option to contribute that year’s full contribution limit instead of a pro-rata amount. You get more tax free medical spending.

As an example, assume I began coverage on June 1st, 2016. Normally, I would only be able to contribute 7/12 (Jun, Jul, Aug, Sep, Oct, Nov, Dec) or just over half of the contribution limit for that year. But since I had coverage on December 1st, I am treated as an eligible individual for the whole year and may contribute up to the full contribution limit.

What is the Testing Period?

However, there is a catch. If you take advantage of the Last Month Rule and choose to contribute more than you normally could have (e.g. 12/12 vs 7/12 above), you are bound by the Testing Period to maintain that coverage for the following year. If you do not, any contribution above the 7/12 you were allowed is considered excessive and taxed and penalized on Line 18 of Form 8889 when you file your taxes. This is generally not good and should be avoided.

Please see this article for a more complete description of the Last Month Rule and Testing Period.

Determining if the Last Month Rule applies to you

First off, let’s relieve a lot of people from worry: if you had the same HSA coverage for each month in a tax year, you can put “0” on Line 18 of Form 8889. Since the Last Month Rule applies only to those who began or changed coverage, you can ignore it and likely go onto something else more enjoyable.

If you had consistent HSA eligible insurance for each month of the year, the Last Month Rule does not apply and you can put “0” on Line 18 of Form 8889.

On the other hand, if you began or changed HSA coverage this year, let’s pose three “yes” or “no” questions to help determine if the Last Month Rule applies to you. You must answer “yes” to the following 3 questions to be eligible to use the Last Month Rule. Answering “no” to any of the following means you can only contribute the pro-rata contribution amount for the months you were HSA eligible.

1) Were you an eligible individual (have HSA eligible coverage) on December 1st of the tax year?

Answering “no” precludes you from using the Last Month Rule as it is a base requirement. This rules out people who, for example, had coverage from January – November of a year, or had coverage from February until August of a tax year. You at least have to have coverage in December to be eligible for the Last Month Rule.

If you answered “yes”, then you may be eligible to use the Last Month Rule, read on.

2) You were HSA eligible (had HSA coverage) for only part of the year?

Answering “no” means you had coverage for the full year, so by definition you can already contribute the HSA maximum contribution limit. You had coverage for 12 months, so can contribute 12/12 or 100% of the contribution limit for the year. You don’t need the Last Month Rule’s help. If this applies to you, put “0” on line 18 of Form 8889.

If you answered “yes”, you likely began coverage mid-year. Perhaps you got a new job and had HSA qualified starting on April 1st, so 9/12 months of the year. Or you had coverage for January through April, then stopped, then had coverage for November and December. If this sounds like your situation, this means that you have the option of using the Last Month Rule for that year. To actually use it, move on to question #3.

3) Did you contribute more than you would otherwise be allowed?

Answering “no” means you contributed less than or equal to your contribution limit based on your months as an eligible individual. So if you had HSA coverage for 5 months, you are allowed to contribute up to 5/12 (41.6%) of the contribution limit without using the Last Month Rule. Doing so plays it safe and avoids any of the requirements or risk of penalty associated with the Testing Period.

Answering “yes” sounds like, “I had HSA coverage for 7/12 months but I contributed the maximum contribution limit using the Last Month Rule”, or “I had coverage for 3/12 months (Oct / Nov / Dec or 25%) but contributed 1/2 (50%) of the maximum contribution limit.” In both of these scenarios, you contributed more to your HSA than you would generally be allowed. This is allowable, as you leveraged the Last Month Rule to make an increased contribution, but remember it has strings attached.

Conclusion

If you answered “No” to any of the 3 questions above, you cannot use the Last Month Rule. You will need to contribute your pro-rata contribution limit based on the number of months you were HSA eligible. You can also put “0” on Line 18 of Form 8889.

If you answered “Yes” to all 3 questions above, you used the Last Month Rule and contributed more than you generally could have. This is allowable but remember you need to maintain HSA coverage for the next year due to the Testing Period. For the current year, you can put 0 on Line 18. If you maintain that HSA coverage through the following year, you will also put “0” on Line 18 of that year’s Form 8889, pass the Testing Period, and hopefully never worry about the Last Month Rule again. Only if you don’t maintain coverage (i.e. fail the Testing Period) will you need to calculate a penalty for Line 18, which will increase your taxable income and add a penalty to your 1040 return.


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